2021071226901 Brown Associates, Inc. CRD 5049 AWC ks.pdf
From April 2021 through at least May 2025, Brown Associates failed to establish,
maintain, and enforce a supervisory system, including written supervisory procedures
(WSPs), reasonably designed to achieve compliance with the firm’s obligations to
conduct reasonable due diligence on private placement offerings sold by the firm to retail
customers. During the same period, Brown Associates failed to identify and reasonably
respond to material discrepancies that appeared in offering documents in several private
placement offerings.